FOR VIOLATIONS OF A 1987 CAFO AND ADDITIONAL NEWLY DIS- COVERED VIOLATIONS OF RCRA, PLAINTIFF IS SEEKING RELIEF CON- SISTING OF AN INJUNCTION REQUIRING DOVER TO 1) CLOSE THE STORAGE AND TREATMENT UNITS IN ACCORDANCE WITH 35 IAC PART 725, SUBPART G, AND 2) CEASE ALL STORAGE AND TREATMENT OF HAZARDOUS WASTE, EXCEPT DURING THE CLOSURE PERIOD, SUCH STORAGE FACILITIES. IN ADDITION, PLAINTIFF IS SEEKING A CIVIL PENALTY UNDER RCRA SECTIONS 3008(C) AND 3008(G) OF $35,000, AND IMPOSITION OF CIVIL PENALTIES AS THE COURT DEEMS APPROPRIATE UP TO $25,000 PER DAY. DOVER INDUSTRIAL CHROME, INC. AND ARIEL G. SCHRODT VIOLATED A CONSENT AGREEMENT AND FINAL ORDER, AND ADDITIONAL RCRA REQUIREMENTS RELATED TO GENERATION, STORAGE, TREATMENT AND CLOSURE.